UNITED STATES ENVIRONMENTAl PROTECTI ON AGENCY WASHI N GTO N , D

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. 20 4 60 

### MAR · 19 

### 2014

MEMORANDUM OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVEN T ION

SUBJECT: Responses to Public Comments Concerning the Registration Review of Methyl Bromide (PC Code 053201) from EPA Docket ID No.: EPA-HQ-OPP-2013- 0269 FROM :

THRU: Bill Chism, Ph.D., Senior Biologist Biological Analys is Branch Cynt hia Doucoure, Environmental Protection Specialist 

## C '**~** Science Information and Analysis Branch Biological and Economic Analysis Division (7503P) Diann Sims, Chief

# ){}!2./L-4-~~**fY~<i)** Science Information and Analysis Branch Amet Jones, Chief /)

# ~~) Biological Analysis

## Branc~, '( Biological and Economic Analysis · i sion (7503P) TO: Susan Bartow, Chemical Review Manager Risk Management and Implementation Branch 4 Pesticide Re-evaluation Division (7508P)
Product Review Panel Da te: February 26, 2014 Through this memo, BEAD is responding to comments about the labe l report and general usage submitted in regards to the registration review of methyl bromide.


### Almond Board of California Comment: The Almond Board provided a description of the use of methyl bromide on almonds for soilpest control as well as post-harve st to control insects in harvested almonds

. They described the use of methyl bromide for control of soil pests of replant disease/disorder, nematodes, and/or other soilpathogens such as oak root fungus (Armillaria) or bacterial canker. They described its post-harvest use for control of Indian meal moth, red flour beetle, and confused flour beetle

. Page 1BEAD Response: BEAD appreciates the updated informat ion on use rates and amounts used for soil and post
-harvest fumigation for California almonds. References direc ting us to relative performance data would be helpful if BEAD is asked to conduct a benefit assessment.
Idaho Potato Commission Comment: The Idaho Potato Commission, the Idaho Grower Shippers Association and the Idaho potato industryprovided information on theirprogram in conjunction with USDA-APHIS to eradicate the Pallida variant of the potato cyst nematode. They describe the sensitive nature of crops like potatoes to soil

- borne pathogens like nematodes and the potentially devastating effect they can have if not properly controlled on yield, quality, and access toforeign markets. BEAD Response : BEAD appreciates the information on the use of methyl bromide fo r potato cyst nematode control and its potential to negatively impact potato production. The EPA works closely with USDA-APHIS to ensure the availability ofeffective control methods for quarantine uses. Methyl Bromide Industrial Panel (MBIP) Postharvest Use Comment: MBIP points out that the majority of post-harvest fumigations with methyl bromide are for the control of quarantine pests on both imported and exportedproducts. BEAD Response: BEAD appreciates the information on the value of methyl bromide for control of quarantine pests on imports and exports
. The EPA works closely with USDA

-APHIS to ensure the availability of methyl bromide for these types of quarantine uses. Methyl Bromide Industrial Panel (MBIP) Pre-plant Soil Use Comment: MBIP points out that the use of methyl bromide has been steadily declining with only California strawberry fruit approved for a critical use exemption in 2014 and that stocks of methyl bromide produced before 2005 are also declining. MBIP stated their concern that the Chemical Profile describes past use and usage information while theypredict future use will be greatly reduced BEAD Response : BEAD understands that MBIP is concerned that the Chemical Profile (Chism, et al, 2013) and SLUA (BEAD, 2012) describe past use and usage. However, the purpose ofthe Chemical Profile is to describe current use, not to predict future use patterns. In the Chemical Profile BEAD agrees with MBIP's assertion of reduced use where the document says that future use will be limited to quarantine and preshipment sites and a few critica l use exemption sites

. As the registration review process continues BEAD will describe currently allowed uses (e.g. quarantine and pre- shipment) and those uses that have been phased out.
Northwest Horticultural Comment: The Northwest Horticultural Councilprovided information on the post-harvest fumigation of cherries to meet the quarantine requirements for export to Australia, Japan, Korea, andNew Zealand. They also described their efforts to find alternatives to methyl bromide for control of quarantine and non -quarantine pests.

Page2BEAD Response: BEAD appreciates the information on current post
-harvest use patterns of methyl bromide and the Council's work to find alternatives. The EPA works closely with USDA-APHIS to ensure the availability of methyl bromide for quarantine uses.
Dr. Joe Noling, University of Florida Comment: Dr. Noting describes th e research on methyl bromide and alternatives, thefumigant safety record , and impacts of buffer zones and educationalprograms. BEAD Response: BEAD appreciates the information on the current research on methyl bromide and alternatives, the safety record offumigants in Florida, and the impacts of buffer zones and educational programs for Florida agriculture. References directing us to relative performance data would be helpful if BEAD is asked to conduct a benefit assessment. American Farm Bureau Federation (AFBF) : The AFBF urges the Agency to permit producers continued access to methyl bromide consistent with Montreal Protocol requirements. I just noticed a comment about the Montreal Protocol/CUEs. It says, "With respect to methyl bromide, we recognize that the Montreal Protocol affects availability and use of this chemical. Nevertheless , given the lack of an affordable , effective alternative, we urge the Agency topermit producers continued access to the chemical cons istent withphase-out dates under the law. AFBF supports the use ofafair, science-basedprocessfor Critical Use Exemptions (CUEs) of methyl bromide. " BEAD Response: BEAD has worked with applicants , the Department of Agriculture, and Department of State for the last twelve years to develop critical use exemptions. The U.S. government continues to submit and defend critical use exemptions for all the app licants that can demonstrate that the alternatives are not technically and economically feasible.
Sources: Almond Board of California. Comments for Methyl Bromide Fumigant Registration Review; Docket: EPA-HQ-20 1 3-0269 -0018. Date: November 25,2013. Gabrie le Ludwig American Farm Bureau. Comments for Methyl Bromide Fumigant Registration Review; Docket: EPA-HQ-2013-0269 -001 2. No Date Chism, W., C. Doucoure , D. Berwald. 2013. BEAD Chemical Profile for Registration Review: Methyl Bromide (053201). Office ofPesticide Programs , U.S. Environmental Protection Agency Idaho Potato Commission. Registration Review; Pesticide Dockets Opened for Review and Comment Docket ID EPA-HQ-OPP

-2013 -0269-00 11. Date: November 25,2013 Methyl Bromide Industry Panel, LLC. Docket: EPA-HQ-OPP-20 13-0269-0015. Post Harvest Uses of Methyl Bromide. Date: November 25, 2013 BEAD. 2012. Methyl bromide (053201) Screening Level Usage Analysis (SLUA), May 30, 2012. Biological and Economic Analysis Division Office of Pesticide Programs , U.S. Environmental Protection Agency
Page 3Methyl Bromide Indu stry Panel, LLC. Dock et: EPA-HQ- OPP-2013-0269-0015 Pre-Plant Soil Uses of Methyl Bromide. Date: N ovember 25 ,2013 Northwest Horticultural Council. Docket: EPA-HQ-OPP-2013-0269 -00 16. Registration Review of Methyl Bromide. Date: November 25, 2013 University of Florida, Institute of Food and Agricultural Sciences. Docket No: EPA-HQ-OPP-2013- 0269-0019. C omments Concerning Noti ce ofOpening ofFumigant Registration Review, 78 Fed

. Reg 59021-59023 , September 25,20 1 3: Docket No: EPA-HQ -OPP-2013:0244 , Ethylene o xide Date: November 25, 20 1 3

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